Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing movement of such data and repealing Directive 95/46/EC (the General Data Protection Regulation) (OJEU L 119/1989, p. 1). (OJEU L 119/1, 04-05-2016) (hereinafter GDPR), provides a modernised and accountability-based framework for the protection of personal data and the accountability framework for data protection in Europe.
In this regard, article 12 of the GDPR, under the heading "Transparency of information, communication and modalities for exercising the data subject's rights", establishes the following in section 1:
The controller shall take appropriate steps to provide the data subject with any information referred to in Articles 13 and 14 and any communication pursuant to Articles 15 to 22 and 34. referred to in Articles 13 and 14, as well as any communication pursuant to Articles 15 to 22 and 34, concerning the processing, in a concise, transparent, intelligible and easily accessible form, in clear and plain language, and processing, in a concise, transparent, intelligible and easily accessible form, in clear and plain language, in particular any information specifically addressed to a child. language, in particular any information specifically addressed to a child. The information shall be provided in writing or by other means, including, where appropriate, by electronic means. Where requested by the information may be provided orally, provided that the identity of the data subject is proved by other means. by other means.
In order to make the greater demand for information introduced by the GDPR compatible with the conciseness and comprehensibility of the way in which it is presented, the Data Protection the way it is presented, the Data Protection Authorities recommend adopting a model of information by layers or levels. information by layers or levels.
The multi-level information approach consists of the following:
- Present basic information at a first level, in summary form, at the same time and in the same medium in which the data is collected. same time and in the same medium in which the data are collected.
- Refer to the additional information on a second level, where the rest of the information will be presented in detail, in a medium more suitable for presentation, comprehension and, if desired, archiving. information, in a medium more suitable for presentation, comprehension and, if desired, archiving.
Data controller: TRACKEND LABS, S.L.
Address of the person in charge: Av. de Brasil, 29 - 1º, 28020, Madrid
Purpose: Your data will be used in order to deal with your requests and to provide you with our services.
Advertising: We will only send you advertisements with your prior consent, which you can provide us with by ticking the appropriate box provided for this purpose.
Legitimation: We will only process your data with your prior consent, which you can provide us with by ticking the appropriate box provided for this purpose.
Addressees: In general, only duly authorised personnel of our organisation may have access to the information we ask for.
Rights: You have the right to know what information we hold about you, to correct it and to delete it, as explained in the additional information available on our website.
YOUR DATA SAFE
Information in compliance with personal data protection regulations.
In Europe and Spain there are data protection regulations designed to protect your personal information that are mandatory for our company.
It is therefore very important to us that you fully understand what we are going to do with the personal data we ask you for.
We will be transparent and put you in control of your data, with plain language and clear choices that allow you to decide what we do with your personal information.
Please do not hesitate to ask us if you have any questions after reading this information.
Thank you very much for your cooperation.
WHO ARE WE?
- Our denomination: TRACKEND LABS, S.L.
- Our CIF / NIF: B-13741723
- Our core business: Technical Engineering Services
- Our address: Av. de Brasil, 29 - 1º, 28020, Madrid
- Our contact telephone number: +34 646 242 726
- Our contact email address: legal[@]trackend.io
- Our website: www.trackend.io
- For your confidence and security, we inform you that we are an entity registered in the following Trade Register / Public Register: B-13741723
We are at your disposal, do not hesitate to contact us.
WHAT ARE WE GOING TO USE YOUR DATA FOR?
In general, your personal data will be used to contact you and to provide you with our services.
They may also be used for other activities, such as sending you advertising or promoting our activities.
WHY DO WE NEED TO USE YOUR DATA?
Your personal data is necessary for us to be able to interact with you and provide you with our services. On In this regard, we will provide you with a series of checkboxes that will allow you to make a clear and simple decision on the use of your personal information. and simple way about the use of your personal information.
WHO WILL KNOW THE INFORMATION WE ASK FOR?
In general, only duly authorised staff of our organisation will be able to obtain knowledge of the information we request from you. information we ask you to provide.
Similarly, your personal information may be disclosed to those entities that need to have access to it in order for us to provide our services to you. access to it so that we can provide you with our services. Thus, for example, our bank will know your details if payment for our services is made by credit card or bank transfer.
Your information will also be disclosed to those public or private entities to which we are obliged to disclose your personal data in order to comply with any law. are obliged to provide your personal data in order to comply with any law. To give you an example, the Tax Law makes it compulsory to provide the Tax Agency with certain information on economic operations over a certain amount. that exceed a certain amount.
In the event that, in addition to the above, we need to disclose your personal information to other entities, we will ask for your permission in advance through clear choices that will allow you to decide whether or not to disclose your personal information to other entities. other entities, we will ask for your prior permission through clear options that will allow you to decide in this regard. in this regard.
HOW WILL WE PROTECT YOUR DATA?
We will protect your data with effective security measures commensurate with the risks associated with the use of your information. information.
To this end, we have approved a Data Protection Policy and annual checks and audits are carried out to ensure that your personal data is secure at all times. and audits are carried out annually to verify that your personal data is secure at all times.
WILL WE SEND YOUR DATA TO OTHER COUNTRIES?
There are countries in the world that are data secure and others that are not. For example, the European Union European Union is a safe environment for your data. It is our policy not to send your personal information to any country that is not safe from a data protection point of view.
In the event that, in order to provide you with the service, it is essential to send your data to a country that is not as secure as Spain, we will always request your prior permission and we will apply security measures. as secure as Spain, we will always ask for your prior permission and we will apply effective security measures to reduce the risks of sending your measures to reduce the risks of sending your personal information to another country.
HOW LONG WILL WE KEEP YOUR DATA?
We will retain your data for the duration of our relationship and for as long as we are required to do so by law. At the end of the applicable legal applicable legal deadlines, we will dispose of it in a secure and environmentally sound manner.
WHAT ARE YOUR DATA PROTECTION RIGHTS?
You may at any time contact us to find out what information we hold about you, rectify it if it is inaccurate and delete it after the end of our relationship, if it is lawful to do so. incorrect, and to delete it after the end of our relationship, where legally possible. possible.
You also have the right to request the transfer of your information to another entity. This right is called "portability" and can be useful in certain situations.
To request any of these rights, you must make a written request to our address, together with a photocopy of your ID card, so that we can identify you. photocopy of your ID card, so that we can identify you.
We have specific forms available at our offices for requesting these rights and we offer you our help in filling them in. We offer you our help in filling them in.
Para saber más sobre sus derechos de protección de datos, puede consultar la página web de la Agencia Española de Data Protection Agency website (www.agpd.es)
CAN YOU WITHDRAW YOUR CONSENT IF YOU CHANGE YOUR MIND AT A LATER STAGE?
You can withdraw your consent if you change your mind about the use of your data at any time.
So, for example, if you were once interested in receiving advertising for our products or services, but you do not wish to receive any more advertising, you can let us know by means of the form of opposition to the treatment available in our offices. form available at our offices.
IF YOU FEEL THAT YOUR RIGHTS HAVE BEEN DISREGARDED, WHERE CAN YOU MAKE A COMPLAINT?
In the event that you feel that your rights have been disregarded by our entity, you may file a complaint with the Spanish Data Protection Agency, by any of the following means complaint to the Spanish Data Protection Agency, by any of the following means:
Electronic headquarters: agpd.es
Spanish Data Protection Agency:
- C/ Jorge Juan, 6
- 28001-Madrid
By telephone:
- Telf. (+34) 901 100 099
- Telf. (+34) 912 663 517
Filing a complaint with the Spanish Data Protection Agency does not entail any cost and it is not necessary to the assistance of a lawyer or solicitor.
DO WE PROFILE YOU?
It is our policy not to profile users of our services.
However, there may be situations where, for service delivery, marketing or other purposes, we need to profile information about you. we need to profile information about you. An example might be the use of your purchase or service history to enable us to offer you products or services tailored to your tastes or needs. needs.
In such a case, we will implement effective security measures to protect your information at all times from unauthorised persons seeking to use it for their own benefit. unauthorised persons intending to use it for their own benefit.
WILL WE USE YOUR DATA FOR OTHER PURPOSES?
It is our policy not to use your data for purposes other than those we have explained to you. If, however we need to use your data for other activities, we will always ask for your permission beforehand by providing you with clear permission in advance by providing you with clear choices that will allow you to decide.
DATA PROTECTION POLICY
The Management / Governing Body of TRACKEND LABS, S.L. (hereinafter, the Data Controller), assumes the utmost responsibility and commitment to the establishment controller), assumes the maximum responsibility and commitment with the establishment, implementation and maintenance of this the establishment, implementation and maintenance of this Data Protection Policy, guaranteeing the continuous improvement of the data controller in order to controller with the aim of achieving excellence in relation to compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data. individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/47/EC. repealing Directive 95/46/EC (General Data Protection Regulation) (OJEU L 119/1, 04-05-2016), and of Spanish personal data protection legislation (Organic Law, sector-specific legislation and its implementing rules). specific legislation and its implementing regulations).
The Data Protection Policy of TRACKEND LABS, S.L. is based on the principle of proactive responsibility, according to which the data controller is responsible for compliance with the proactive responsibility principle. proactive responsibility, according to which the data controller is responsible for the compliance the regulatory and jurisprudential framework that governs said Policy, and is able to demonstrate it to the competent control authorities. competent supervisory authorities.
In this regard, the controller shall be governed by the following principles which should serve as a guide and framework for all its staff in the processing of personal data personnel as a guide and frame of reference in the processing of personal data:
- Data protection by design: the controller shall implement, both at the time of determining the means of processing and at the time of the processing itself, technical and at the time of the determination of the means of processing and at the time of the processing itself, appropriate technical and organisational measures, such as pseudonymisation, designed to measures, such as pseudonymisation, designed to implement effectively the principles of data protection, such as the minimisation of the use of pseudonymisation. data protection principles, such as data minimisation, and integrate the necessary safeguards into the processing. processing.
- Data protection by default: the controller shall implement appropriate technical and organisational measures with a view to ensuring that, by default, only data that are processed by default are processed. organisational measures with a view to ensuring that, by default, only those personal data are processed which are necessary for each of the specific purposes of the processing. necessary for each of the specific purposes of the processing.
- Data protection in the information lifecycle: measures ensuring the protection of personal data shall apply throughout the entire information lifecycle. of personal data shall apply throughout the entire lifecycle of the information.
- Lawfulness, fairness and transparency: personal data shall be processed lawfully, fairly and transparently in relation to the data subject. transparent in relation to the data subject.
- Purpose limitation: Personal data will be collected for specified, explicit and legitimate purposes and will not be further processed in a way incompatible with those purposes. legitimate purposes and will not be further processed in a way incompatible with those purposes.
- Data minimisation: Personal data will be adequate, relevant and limited to what is necessary for the purposes for which they are processed. in relation to the purposes for which they are processed.
- Accuracy: personal data shall be accurate and, where necessary, kept up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate or incomplete are deleted or rectified without delay. reasonable steps shall be taken to ensure that personal data which are inaccurate with regard to the purposes for which they are processed are inaccurate in relation to the purposes for which it is processed.
- Limitation of the retention period: the personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. the personal data.
- Integrity and confidentiality: personal data shall be processed in such a way as to ensure adequate security of the personal data, including protection against unauthorised or appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or unlawful processing and against accidental loss, destruction or damage by appropriate technical or organisational measures. appropriate technical or organisational measures.
- Information and training: One of the keys to guaranteeing the protection of personal data is the training and information provided to the personnel involved in their processing. the training and information provided to the personnel involved in the processing of personal data. During the life cycle of the information, all personnel with access to the data shall be properly trained and informed about their obligations in relation to the protection of personal data. and informed of their obligations in relation to compliance with data protection regulations. data protection regulations.
The Data Protection Policy of TRACKEND LABS, S.L. is communicated to all the staff of TRACKEND LABS, S.L. and made available to all interested parties. and made available to all interested parties.
Consequently, this Data Protection Policy involves all the staff of the data controller, who must be aware of it and accept it as their own. data controller, who must know and accept it, considering it as their own, with each member being responsible for its applying it and verifying the data protection regulations applicable to their activity, as well as identifying and providing the opportunities for improvement that they consider appropriate with the aim of achieving excellence in relation to their compliance. in relation to its compliance.
This policy shall be reviewed by the Management / Governing Body of TRACKEND LABS, S.L., as many times as deemed necessary, in order to as many times as deemed necessary, in order to adapt, at all times, to the provisions in force regarding the protection of personal protection of personal data.